IMPPA WELFARE TRUST ,MUMBAI vs. ITO (EXEMPTIONS) WARD 1(3), MUMBAI

ITA 1999/MUM/2026Status: DisposedITAT Mumbai08 June 20267 pages
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What were the facts?

The assessee trust applied for renewal of registration under section 12AB and approval under section 80G. The CIT(E) rejected both applications citing the absence of an explicit irrevocability clause and dissolution clause in the trust deed. Subsequently, the assessee obtained fresh registration under section 12AB.

What did the Tribunal hold?

The Tribunal held that the appeal challenging the rejection of 12AB registration has become infructuous as fresh registration was granted. For the 80G approval, it was remanded to the CIT(E) to consider granting approval, as the rejection was consequential to the 12AB rejection.

What were the issues?

Whether the absence of an explicit irrevocability and dissolution clause in the trust deed is a valid ground for rejecting renewal of registration under section 12AB. Whether the rejection of 80G approval is sustainable when the basis for it (rejection of 12AB registration) is subsequently rectified.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G,Section 12A(1)(ac)(ii),Section 11,Section 60,Section 61,Section 62,Section 63,Section 12AB(4)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH MUMBAI

Before: SHRI ANIKESH BANERJEE& SHRI MAKARAND VASANT MAHADEOKAR

For Appellant: Shri Mitali Parekh, Ld. AR
For Respondent: Shri R. A. Dhyani, Ld. DR
Hearing: 14.05.2026Pronounced: 08.06.2026

Heard together (2 matters)

ITA No. 1999/Mum/2026
ITA No. 2000/Mum/2026

Read from the judgment's own cause title. This page is filed under one of them.

PER MAKARAND VASANT MAHADEOKAR, AM: These two appeals are directed against separate orders passed by the Commissioner of Income Tax (Exemptions), Mumbai [hereinafter referred to as “the CIT(E)”], both dated 18.02.2026, whereby the application of the assessee-trust seeking renewal of registration under section 12AB of the Income Tax Act, 1961 (“the Act”) and consequential application seeking approval under section 80G of the Act came to be rejected.Since the issues involved in both the appeals arise out of common facts and were hea

The order continues below.

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